The entity that earned the online revenue must be determined from the contractual and commercial facts, not solely from which company received the cash. Relevant factors include which entity contracted with customers, controlled the inventory, set prices, bore return and credit risks, issued invoices, and remained responsible for fulfilment. A marketplace account held by a foreign parent or local affiliate may indicate a legacy arrangement, an agency relationship, or an actual sale by that entity. The bank recipient alone does not conclusively establish revenue ownership.
Evidence Needed to Determine Entity Attribution
A PT PMA online sales legal entity review should examine marketplace merchant agreements, website terms, payment gateway contracts, bank ownership, customer invoices, inventory purchase documents, warehouse records, import documents, and intercompany agreements. Transaction flows should establish whether another group company collected funds as an agent, sold goods as principal, or supplied inventory to the PT PMA. Accounting entries must then reflect receivables, settlement balances, expenses, and intercompany amounts consistently with that arrangement. Entity mismatches can affect revenue recognition, PPN, PPh, customs records, and related-party reporting, but they do not automatically establish non-compliance. Where contracts and operational conduct conflict, legal, accounting, and tax analysis may be needed before reallocating revenue or correcting an SPT.